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Washington Debrief: MACRA Reg is Out!

May 2, 2016
by Leslie Kriegstein, Vice President of Congressional Affairs, CHIME
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Federal Affairs:

Key Takeaway: The MACRA proposed regulation has hit the street.  CMS published it April 27th.   

Why it Matters: In an unusual move, CMS published the long-anticipated proposed rule on the Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) program stemming from the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) of 2015. Collectively, CMS is referring to these programs as the Quality Payment Program. CMS says their goal with the Quality Payment Program is to continue to support health care quality, efficiency, and patient safety.

MACRA reforms the long-time sustainable growth rate formula dictating the way physicians and other clinicians are paid and replaces it with a new system that rewards value and outcomes.  The law also consolidates the current Meaningful Use, Physician Quality Reporting System, and Value-based Payment Modifier programs.  Components of each are a part of the new system. 

CMS states they are, “focused on three core strategies to drive continued progress and improvement.” These include: 1) Focusing on improving the way clinicians are paid to incentivize quality and value of care over simply quantity of services; 2) improving the way care is delivered by providing clinical practice support, data and feedback reports to guide improvement and better decision-making; and 3) making data more available and enabling the use of certified EHR technology to support care delivery.  Below is a high-level overview of some of the key pieces:

  • Reporting: Full, calendar year reporting (2017 performance year for 2019 payment)
  • Applies to: Medicare Part B clinicians, including physicians, physician assistants, nurse practitioners, clinical nurse specialist, and certified registered nurse anesthetists.
  • The Score: Clinicians will be assessed on a 100 point scale known as the Composite Performance Score or CPS:
    • Quality: 50% of total score
    • Resource Use: 10% of total score
    • Clinical Practice Improvement Activities (CPIA): 15% of total score
    • Advancing Care Information (formerly Meaningful Use): 25% of total score
  • The Program Formerly Known as MU: Is now “Advancing Care Information” (see pages 198-235 of the rule)
    • 25 percent of total CPI score
    • ACI made up of a total of 100 points involving two main areas: 1) base score (50%); 2) performance score (80%); and 3) chance for a bonus point for public health and clinical data registry reporting
    • Way to exceed 100 points but if you do you just get full 25% ACI category
    • Base Score involves reporting the numerator (of at least one) and denominator for 6 objectives comprising 11 measures total plus an option to meet 4 additional public health reporting measures [SEE TABLE 6 of the rule]
    • Failing to attest to meet any submission criteria and measure specifications for any measure results in a score of zero for the entire ACI category.
    • To receive the base score, clinicians must provide the numerator/denominator or yes/no for each objective and measure. Only “yes” responses count.
    • CMS has proposed removing the thresholds that apply under Stage 3. The performance score would be calculated based performance on eight measures for a total of 80 points with up to ten percent per measure.  Clinicians select the measures that best fit their practice. Example – Clinicians sends 31% of their patients (or responds) a secure message, the score under secure messaging would be 3.1%.  [SEE TABLE 9 for a sample performance score]





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Security Risk Analysis


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Patient Electronic Access

  1. ePrescribing
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  3. Patient-Specific Education


Coordination of Care Through Patient Engagement

  1. View, Download or Transmit (VDT)
  2. Secure Messaging
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Health Information Exchange

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Public Health and Clinical Data Registry Reporting

Immunization Registry Reporting

(Optional) Syndromic Surveillance Reporting

(Optional) Electronic Case Reporting

(Optional) Electronic Case Reporting

(Optional) Public Health Registry Reporting



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